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#1403937 - 06/15/10 06:17 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
Valley Girl
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Posts: 142
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#1415782 - 07/15/10 11:29 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
Valley Girl
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Gold Star
Joined: Feb 2006
Posts: 389
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Hello all. I read through this thread and I know a few people have stated this but I'm just curious as to how many people have just taken the stance that their bank will not offer this product. That has been our stance and I'm wondering how much company we have. Thanks!
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#1415880 - 07/16/10 02:03 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
Confused Banker
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Joined: Jul 2001
Posts: 84,371
Galveston, TX
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Most, if not all of my clients have quit.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1415963 - 07/16/10 03:28 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
rlcarey
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Joined: Feb 2006
Posts: 389
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Good to know, thanks. We rarely get requests for this purpose in (we don't do a lot of consumer purpose lending) so we did our best on the first two that we did receive. It is just too labor intensive to be profitable but I just wanted to make sure we were not the only ones who came to that conclusion.
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#1416057 - 07/16/10 05:33 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
Confused Banker
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Power Poster
Joined: Aug 2001
Posts: 7,364
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Yesterday, we had a loan request for a loan to pay tuition to a firefighter's academy. Thankfully, the applicants changed their minds in favor of a refrigerator purchase. ;o)
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The more you sweat in training, the less you bleed in battle.......
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#1416318 - 07/16/10 09:11 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
Confused Banker
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Platinum Poster
Joined: Sep 2007
Posts: 937
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We quit. With the passage of the "financial reform" bill job security never felt so good.
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#1422545 - 08/01/10 05:05 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
rlcarey
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Power Poster
Joined: Jun 2001
Posts: 8,272
Where the heart is
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Most, if not all of my clients have quit. Same here - except those credit unions that use "open-end" LoanLiner.
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CRCM,CAMS Regulations are a poor substitute for ethics. Just sayin'
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#1426525 - 08/10/10 03:12 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
Princess Romeo
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Gold Star
Joined: Jan 2008
Posts: 285
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I've read through the thread and have still yet to find a solid answer.
We are no longer offering any types of PEL unless secured by real estate or open-end; but we have a loan we made 5 years ago, secured by stock, that is up for renewal in a few days.
If it is just a renewal/extension do we need to do any of the disclosures?
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#1426574 - 08/10/10 03:34 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
iliniyak
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10K Club
Joined: Jul 2001
Posts: 84,371
Galveston, TX
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1426577 - 08/10/10 03:35 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
rlcarey
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#1426859 - 08/10/10 07:37 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
swiggles
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Gold Star
Joined: Nov 2008
Posts: 498
Texas
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Yesterday, we had a loan request for a loan to pay tuition to a firefighter's academy. Thankfully, the applicants changed their minds in favor of a refrigerator purchase. ;o) Funny thing, that seems to be happening here also... We quit making these loans as well. We politely tell the customer we are no longer able to make these types of loans. Please feel free to write their local representatives.
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#1427090 - 08/11/10 12:24 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
Duke
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Joined: Jul 2001
Posts: 84,371
Galveston, TX
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Yes they are covered as collateral has no bearing unless secured by real property. If any of these loans to which you speak are for $10,000 or more, not asking the purpose of the loan violates the BSA regulations:
Sec. 103.33 Records to be made and retained by financial institutions
Each financial institution shall retain either the original or a microfilm or other copy or reproduction of each of the following:
(a) A record of each extension of credit in an amount in excess of $10,000, except an extension of credit secured by an interest in real property, which record shall contain the name and address of the person to whom the extension of credit is made, the amount thereof, the nature or purpose thereof, and the date thereof;
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com
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#1434735 - 08/26/10 05:09 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
lucyc
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Joined: Jul 2007
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#1434970 - 08/26/10 07:36 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
lucyc
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#1435001 - 08/26/10 08:00 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
lucyc
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Platinum Poster
Joined: Feb 2010
Posts: 960
Illinois
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I'm not sure how you can fix it at this point, other than to properly disclose it now. The troubling issue is that they have the right to cancel without penalty up to three days after receiving the disclosures.
Are you sure they weren't just buying a refrigerator?
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I thought getting old would take longer.
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#1462273 - 11/02/10 12:22 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
FABCompliance
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100 Club
Joined: Apr 2010
Posts: 103
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Could you email a copy of the application disclosure?
marybrit.milwee@bankofharlan.com
Thanks,
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#1462679 - 11/02/10 07:17 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
perplexed1
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100 Club
Joined: Jul 2006
Posts: 149
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Are we required, or permitted, to redisclose an approval disclosure that has been accepted based on a change made by the school? For example, the school changes the number of disbursements or the expected graduation date. Disbursement date changes seem to be discussed in the commentary, but other scenarios in which the school could make a change do not seemt o be addressed. Thanks!
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#1498772 - 01/21/11 08:32 PM
Re: FRB 3/11 ANPR Reg Z Amend on College Student Loans
goingtoexperts
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100 Club
Joined: Feb 2008
Posts: 142
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I am also curious about the maximum rate when you have a fixed rate loan. If it is fixed rate then is the default rate of 18% disclosed or our state's maximum which is 21%?
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